LOTON, CORP.
13499 RUE HUNTINGTON, QC, H8Z1G3, CANADA
Tel. 1(438)8701351
Fax. 1(450)9881288
E-mail: lotoncorp@yahoo.com
September 14, 2010
United States
Securities and Exchange Commission
Washington, DC 20549
To the Attention of: Mr. Ryan Houseal, Ms. Maryse Mills-Apenteng.
Re: Loton, Corp.
Amendment No. 2 to Registration Statement on Form S-1,
Filed on August 24, 2010
Filing No. 333-167219
Dear Mr. Ryan Houseal, Ms. Maryse Mills-Apenteng:
Further to your letter dated September 10, 2010, concerning the deficiencies in Amendment No.2 to Registration Statement on Form S-1 filed on August 24, 2010, we provide the following responses:
Management’s Discussion and Analysis or Plan of Operations, page 22
Plan of Operation, page 23
1. SEC Comment: While you initially estimate the costs of “commencing your marketing campaign” to be $2,000, your tabular disclosure of your estimated costs over the next 12 months lists your marketing costs at $1.000. Please revise this discrepancy or advise.
Response: We revised the estimated costs of commencing our marketing campaign and made necessary changes. Please refer to page 23 of the prospectus:
Commence Marketing Campaign. Time Frame: 8th-12th months. Estimated cost $1,000.
We intend to use marketing strategies, such as web advertisements, direct mailing, and phone calls to acquire potential customers. We also expect to get new clients from "word of mouth" advertising where our new clients will refer their colleagues to us. We will encourage such advertising by rewarding person who referred new clients to us.
We also plan to attend shows and exhibitions in architectural and construction industries, which help architects, builders, advertising agencies, interior designers, home renovators, home owners and various sectors which have need of 3D visualization in Canada come face to face and find new business opportunities and partners. We intend to spend about $1,000 on marketing efforts during the first year. Marketing is an ongoing matter that will continue during the life of our operations.
Marketing costs | $1,000 |
Website development costs | 3,000 |
PCs purchase | 6,500 |
Software purchase | 4,500 |
Audit and accounting fees | 4,000 |
Office Set Up | 2,000 |
Other | 1,000 |
Total | $22,000 |
Please direct any further comments or questions you may have to the company's president Mr. Alex Kuznetsov at:
13499 Rue Huntington
Pierrefonds, QC, H8Z1G3, Canada
Tel. 1(438)8701351
Fax. 1(450)9881288
Thank you.
Sincerely,
/S/ Alex Kuznetsov
Alex Kuznetsov, President